Open-ended Credit Disclosures & HMDA Reporting

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Question:

For a consumer-purpose, revolving line of credit, are we still required to disclose the same information normally found in the fed box on regular notes - APR, Amt Financed, etc? If we have a non-consumer that is getting a loan to purchase or build a single family residence for resale, do we include them on our HMDA report?

Answer:

Disclosures for open ended credit products are under 226.5 and 226.5a. These will include the interest rates, various fees, grace period, contact information, etc. The disclosure content and format will vary from standard loans and will be based on your product.

Your second question involves HMDA reporting. Construction and temporary financing is not HMDA reportable unless you are also doing the permanent financing.

First published on BankersOnline.com 08/12/02